Finding 1073907 (2023-001)

2023-001 - Internal Controls over Subrecipient Monitoring (SD, NC) Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Federal Catalog Number: 21.027 Federal Agency: U.S. Department of Treasury Category of Finding: Subrecipient Monitoring Criteria: Pursuant to the Office of Management and Budget (OMB) 2 CFR Part 200, Appendix XI, Compliance Supplement May 2023, sections 3-M-1 and 3-M-2: A recipient must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Condition: While the Society currently has policies and procedures for monitoring subrecipients, it does not have a policy specifically relating to subaward agreements between the Society and its subrecipients that is compliant with applicable Federal statutes per 2 CFR part 200, Appendix XI, Compliance Supplement May 2023, sections 3-M-1 and 3-M-2. No formal subaward agreement was drafted by the Society and its subrecipient. Cause: Lack of formal policies specifically addressing federal requirements for subaward agreements. Effect or Potential Effect: Although the Society has existing policies and procedures for monitoring, the absence of a formal subaward agreement compliant with federal regulations may potentially result in the Society sending funds to subrecipients for activities and services that are nonconforming to allowed costs under the Uniform Guidance. Questioned Cost: None Context: During the audit, we did not receive a copy of the subaward between the Society and its subrecipient. Repeat of a Prior-Year Finding: No.